(delivering the Judgment of the Court) The appellant, an Indonesian, and the respondent, a Singaporean, are shareholders and directors of ASPA Shipyard Pte. Ltd. ("the Company"). The company was incorporated in Singapore on May 14, 1974 and has an authorised capital of $ 2,000,000 divided into 2,000,000 shares of $ 1 each, of which 200,000 shares have been issued and are fully paid. Initially, the 200,000 shares were held as to 190,000 shares by the appellant and 10,000 shares by the respondent. According to the appellant, the funds for the entire issued share capital were provided by him and the 10,000 shares were given by him to the respondent, who was essentially his assistant. Soon after its incorporation, the Company purchased office premises at the International Plaza, Anson Road, including the premises where it presently carries on business, namely, Unit 816-817, 8th floor, International Plaza, Anson Road, Singapore 0207, and also other properties, including shares in quoted companies and a motor vehicle. The funds for the purchase of all these properties came from the companys capital and loans from financial institutions and from the appellant himsel